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RE: Gov't Response to Motion for Interrogatories



Sir-

  You're right.  Under the NMCCA rules we don't have a response as a matter of right, although we can file a motion for leave to file a response.  I doubt it's worth bothering.

  I've sent out everything I've received.  As far as I know, there's been no response to the motion for access.

v/r
Sip

-----Original Message-----
From: Sullivan, Dwight H CIV USAF AFLOA/JAJA [mailto:Dwight.Sullivan@pentagon.af.mil] 
Sent: Monday, June 20, 2011 9:36
To: Sripinyo, Kirk Major NAMARA, CODE 45; Marshall Maj Meridith L; dhsullivan@aol.com; haytham@puckettfaraj.com
Cc: neal@puckettfaraj.com; babu_kaza@hotmail.com; ksripinyo@yahoo.com
Subject: RE: Gov't Response to Motion for Interrogatories

Maj Sip,

My understanding is that under NMCCA's Rules, we don't have a right to reply
to this.  Is that correct?  If not, I don't think we should move for leave
to file a reply.  But boy does Keller miss the boat.  He seems to be whining
about having lost the fight on the stay rather than addressing the merits of
the request for interrogatories.  I doubt NMCCA will grant our motion -- but
not due to anything Keller said!

Did Code 46 ever file a response to our motion for access to the sealed
record of the ex parte hearing?

Semper Fi,
DHS

Dwight H. Sullivan
Senior Appellate Defense Counsel
Air Force Appellate Defense Division
(AFLOA/JAJA)
1500 West Perimeter Road, Suite 1100
Joint Base Andrews, MD 20762
240-612-4773
DSN:  612-4773
Fax:  240-612-5818  


-----Original Message-----
From: Sripinyo, Kirk Major NAMARA, CODE 45 [mailto:kirk.sripinyo@navy.mil] 
Sent: Friday, June 17, 2011 9:41 AM
To: Marshall Maj Meridith L; dhsullivan@aol.com; haytham@puckettfaraj.com
Cc: neal@puckettfaraj.com; Sullivan, Dwight H CIV USAF AFLOA/JAJA;
babu_kaza@hotmail.com; ksripinyo@yahoo.com
Subject: Gov't Response to Motion for Interrogatories

Team Wuterich-

  Here's is the government's response to the subject motion.  I'll be out of
the office this afternoon, but reachable via my civilian email:
ksripinyo@yahoo.com

v/r
Sip

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